The defendant corporation was charged with unlawfully disposing of oil field fluids in violation of the Oil, Gas and Salt Resources Act and related regulations.
The Crown sought to admit a Certificate of Analysis from Maxxam Analytics containing chemical analysis results of soil and vegetation samples collected from the defendant's well site.
The defendant objected to admission of the document as hearsay.
The court conducted a voir dire to determine admissibility under the business records exception to the hearsay rule under section 35 of the Ontario Evidence Act.
The court found that the Certificate of Analysis met all requirements for admission as a business record and admitted it into evidence.
